Opinion
Case No. 3:12-cr-00049
03-26-2013
UNITED STATES OF AMERICA v. REBECCA P. SULLIVAN
Senior Judge Nixon
MOTION TO CONTINUE SENTENCING HEARING
COMES NOW the Defendant, Rebecca P. Sullivan, by and through her undersigned counsel, and respectfully requests that this Honorable Court continue the sentencing hearing in her case from Friday, March 29, 2013 at 10:30 a.m., to a later date convenient to the Court and counsel at least six months from now. In support hereof, Defendant states as follows:
1. The sentencing hearing in this case is currently scheduled for Friday, March 29, 2013 at 10:30 a.m. (Docket Entry 24).
2. Undersigned counsel will supplement this filing with an in camera affidavit reciting the reasons for the continuance request.
3. Assistant United States Attorney Kathryn B. Ward has authorized undersigned counsel to report that the government does riot oppose this motion.
WHEREFORE, based on the foregoing, Defendant Sullivan respectfully requests that this Honorable Court continue the sentencing hearing in her case from Friday, March 29, 2013 at 10:30 a.m., to a later date convenient to the Court and counsel at least six months from now.
Respectfully submitted,
TUNE, ENTREKIN & WHITE, P.C.
Suite 1700, Regions Center
315 Deaderick Street
Nashville, Tennessee 37238
(615) 244-2770
______________________
PETER J. STRIANSE
Attorney for Defendant
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been sent via the Court's electronic filing system unless not registered and, in that event deposited in the United States mail, postage prepaid, to:
Kathryn B. Ward
Assistant Unilled States Attorney
110 Ninth Avenue South
Suite A961
Nashville, TN 37203-3870
______________________
PETER J. STRIANSE